Weiss v. State of New York

CourtCourt of Appeals for the Second Circuit
DecidedJune 5, 2024
Docket22-2326
StatusUnpublished

This text of Weiss v. State of New York (Weiss v. State of New York) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Weiss v. State of New York, (2d Cir. 2024).

Opinion

22-2326-cv Weiss v. State of New York, et al.

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING TO A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 5th day of June, two thousand twenty-four.

PRESENT: JON O. NEWMAN, SARAH A. L. MERRIAM, Circuit Judges. GARY S. KATZMANN, Judge. * __________________________________________

PATRICIA WEISS,

Plaintiff-Appellant,

v. No. 22-2326-cv

STATE OF NEW YORK; HONORABLE JUSTICE JAMES HUDSON; JOHN BUSIELLO,

Defendants-Appellees. __________________________________________________

* Judge Gary S. Katzmann, of the United States Court of International Trade, sitting by designation. FOR PLAINTIFF-APPELLANT: PATRICIA WEISS, Sag Harbor, NY.

Appeal from an order of the United States District Court for the Eastern District of

New York (Brown, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the September 27, 2022, order of the District Court is

AFFIRMED.

Plaintiff-appellant Patricia Weiss, a self-represented attorney, appeals from the

September 27, 2022, order of the District Court sua sponte dismissing her complaint for

lack of subject matter jurisdiction. We assume the parties’ familiarity with the underlying

facts, procedural history, and issues on appeal, to which we refer only as necessary to

explain our decision.

Acting New York Supreme Court Justice James Hudson imposed sanctions on

Weiss in connection with a state court nuisance action in which Weiss represented

nonparty plaintiffs against John Busiello. See Whelan v. Busiello, 195 N.Y.S.3d 87 (2d

Dep’t 2023). Weiss thereafter commenced this action for declaratory and injunctive relief

pursuant to 42 U.S.C. §1983 against Acting Justice Hudson, Busiello, and the State of

New York. Weiss’s complaint asserted various civil rights violations and challenged the

constitutionality of several New York State statutes and regulations governing the

imposition of sanctions. Two days after Weiss filed the fee-paid complaint, the District

2 Court sua sponte dismissed the complaint for lack of subject matter jurisdiction based on

the Rooker-Feldman and Younger abstention doctrines. 1 Weiss timely appealed.

We review de novo a district court’s legal determination as to the existence of

subject matter jurisdiction. See A&B Alt. Mktg. Inc. v. Int’l Quality Fruit Inc., 35 F.4th

913, 915 (2d Cir. 2022); see also Disability Rts. N.Y. v. New York, 916 F.3d 129, 133 (2d

Cir. 2019) (“We review de novo the essentially legal determination of whether the

requirements for abstention have been met.” (citation and quotation marks omitted)).

Because Weiss is an attorney, she is not entitled to the special solicitude ordinarily

extended to self-represented litigants. See Tracy v. Freshwater, 623 F.3d 90, 102 (2d Cir.

2010).

We have previously recognized that a sua sponte dismissal without notice is a “bad

practice in numerous contexts” and can be independent “grounds for reversal.” Catzin v.

Thank You & Good Luck Corp., 899 F.3d 77, 82-83 (2d Cir. 2018) (citation and quotation

marks omitted); see also, e.g., Brookins v. Figuccio, No. 22-731-cv, 2023 WL 2579043,

at *2 (2d Cir. Mar. 21, 2023) (summary order) (vacating no-notice sua sponte dismissal

and remanding for further proceedings); Nwoye v. Obama, No. 22-1253-cv, 2023 WL

382950, at *1-2 (2d Cir. Jan. 25, 2023) (summary order) (same). Nevertheless, we have

also recognized that such dismissals may be permissible where, inter alia, “it is

unmistakably clear that the court lacks jurisdiction.” Catzin, 899 F.3d at 82 (citation and

1 These doctrines stem from Supreme Court decisions bearing the same names. See generally Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923); D.C. Ct. of Appeals v. Feldman, 460 U.S. 462 (1983); Younger v. Harris, 401 U.S. 37 (1971).

3 quotation marks omitted). While permitting Weiss to respond to the defects in her

complaint would have been preferable, we nonetheless conclude that vacatur is not

warranted because the District Court properly abstained under Younger. 2

The Younger abstention doctrine provides that “federal courts should generally

refrain from enjoining or otherwise interfering in ongoing state proceedings.” Spargo v.

N.Y. State Comm’n on Jud. Conduct, 351 F.3d 65, 74 (2d Cir. 2003). Younger abstention

applies to (1) state criminal prosecutions, (2) civil enforcement proceedings akin to

criminal prosecutions, and (3) civil proceedings that implicate a state’s interest in

enforcing the orders and judgments of its courts. See Sprint Commc’ns, Inc. v. Jacobs,

571 U.S. 69, 72-73 (2013).

Weiss’s complaint unmistakenly falls within the third category because (1) the

state proceedings remain pending, (2) those proceedings implicate an important state

interest, namely, New York’s interest in enforcing the orders of its courts, and (3) the

complaint in this action attacks the state court’s ability to impose sanctions on litigants

and attorneys practicing before it, including Weiss. 3 See Disability Rts. N.Y., 916 F.3d at

133; see also Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423,

2 We agree with Weiss that the District Court incorrectly relied on the Rooker-Feldman doctrine in dismissing the complaint. State proceedings are insufficiently final to trigger Rooker-Feldman when, as here, an appeal before the state court remains pending. See Hunter v. McMahon, 75 F.4th 62, 70-71 (2d Cir. 2023). Nevertheless, “we may affirm on any ground supported by the record,” NXIVM Corp. v. Ross Inst., 364 F.3d 471, 476 (2d Cir. 2004), and Younger abstention remains a sound basis for dismissal. 3 Indeed, Weiss specifically sought injunctive and declaratory relief that would interfere with the resolution of the matter in state court by, for instance, barring the application of the statutes and rules under which sanctions were assessed against her.

4 434-35 (1982) (“The State’s interest in the professional conduct of attorneys involved in

the administration of criminal justice is of special importance . . . and . . .

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Related

Rooker v. Fidelity Trust Co.
263 U.S. 413 (Supreme Court, 1924)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Juidice v. Vail
430 U.S. 327 (Supreme Court, 1977)
District of Columbia Court of Appeals v. Feldman
460 U.S. 462 (Supreme Court, 1983)
Tracy v. Freshwater
623 F.3d 90 (Second Circuit, 2010)
Sprint Commc'ns, Inc. v. Jacobs
134 S. Ct. 584 (Supreme Court, 2013)
NXIVM Corp. v. Ross Institute
364 F.3d 471 (Second Circuit, 2004)
Catzin v. Thank You & Good Luck Corp.
899 F.3d 77 (Second Circuit, 2018)
Disability Rights N.Y. v. New York
916 F.3d 129 (Second Circuit, 2019)
Weinstein v. Bogacz
320 F. App'x 56 (Second Circuit, 2009)
Hunter v. McMahon
75 F.4th 62 (Second Circuit, 2023)
Whelan v. Busiello
219 A.D.3d 778 (Appellate Division of the Supreme Court of New York, 2023)

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Weiss v. State of New York, Counsel Stack Legal Research, https://law.counselstack.com/opinion/weiss-v-state-of-new-york-ca2-2024.